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Before the
Federal Communications Commission
Washington, D.C.
In the Matter of )
)
Revision of the Commission's Rules )
To Ensure Compatibility with ) CC Docket No. 94-102
Enhanced 911 Emergency ) RM-8143
Calling Systems )
Order
Adopted: September 30, 1998; Released: September 30, 1998
By the Chief, Wireless Telecommunications Bureau:
1. The Cellular Telecommunications Industry Association (CTIA) and the Personal
Communications Industry Association (PCIA), in a letter sent to the Wireless
Telecommunications Bureau (Bureau) on September 11, 1998, have requested that the
Bureau grant a three-month extension of the deadline for compliance with the provisions of
Section 20.18(c) of the Commission's Rules, relating to the transmission of 911 calls through
the use of TTY devices. For the reasons discussed below, we deny this request, but grant a
more limited suspension of the enforcement of the rule for purposes of accomplishing the
objectives we discuss in this Order.
2. The Commission adopted a rule in the E911 First Report and Order in the above
captioned rulemaking proceeding requiring that, as of October 1, 1997, all covered carriers
must be capable of transmitting 911 calls from individuals with speech or hearing disabilities
through means other than mobile radio handsets, e.g., through the use of text telephone
(TTY) devices. The Commission, in adopting the rule, also recognized certain potential
technical difficulties raised in the record. Nonetheless, in light of a consensus agreement
among public safety and wireless industry representatives addressing this and other issues in
the proceeding, the Commission adopted the requirement to take effect one year after the
effective date of the rules and urge all parties to work together to resolve any technical
difficulties. Several parties filed petitions for reconsideration of the TTY requirements for
digital mobile radio systems because of their claim that digital systems may not be
compatible with TTY devices.
3. On December 1, 1997, in adopting the E911 Reconsideration Order, the
Commission affirmed its decision that licensees providing wireless services would be
required to transmit 911 calls made by individuals with speech or hearing disabilities.
Recognizing the technical difficulties associated with transmitting TTY calls on digital
wireless systems, however, the Commission suspended enforcement of this requirement until
October 1, 1998, for all TTY/911 calls made on digital systems. In making this decision,
the Commission indicated that the additional time would allow the wireless industry
working with organizations representing individuals with hearing and speech disabilities to
overcome technical barriers and compatibility problems involved in implementing solutions
for TTY users on digital wireless systems. The Commission, in its decision, also
delegated to the Bureau the authority to grant up to a three-month extension of the October
1, 1998, deadline (i.e., to January 1, 1999).
4. Since September, 1997, the Wireless TTY Forum (Forum) an organization
consisting of wireless carriers and equipment manufacturers, manufacturers of TTY
equipment, emergency and relay service providers, and consumer organizations representing
individuals who are deaf or hard-of-hearing has met on seven occasions in an effort to
develop solutions that will enable TTY users to make 911 calls on digital networks. The
Forum, however, has thus far been unable to achieve such solutions. Consequently, CTIA
and PCIA, in the September 11 Letter, have requested that the Bureau grant a three-month
extension of the deadline. In their letter, CTIA and PCIA note that CMRS carriers offering
digital wireless services will not be able to comply with the FCC's rules governing TTY
access to 9-1-1 over digital wireless systems by October 1, 1998.
5. In support of their request, CTIA and PCIA briefly discuss certain conclusions
reached by the Forum during the past year, and provide a draft workplan for the Forum's
future activities. In particular, the draft workplan identifies actions that are intended to result
in the development of short-term and long-term solutions. Unfortunately, the draft
workplan does not provide specific estimates for when such solutions might be
implemented. In addition, CTIA and PCIA acknowledge that the workplan has not been
reviewed by the various groups participating in the Forum, i.e., consumer organizations,
TTY manufacturers, public safety answering point (PSAP) organizations, and wireless
equipment manufacturers.
6. The Bureau does not believe that CTIA and PCIA have provided adequate
justification for granting the requested extension. While we recognize that the members of
the Forum must resolve difficult issues before solutions can be achieved and that efforts have
been made by Forum participants in this regard, we also cannot ignore the fact that the
Forum has been in existence for a full year, and only in the past month has it been able to
develop a draft plan for the testing of digital wireless phones, as a first step in defining the
scope of the problems to be solved.
7. The Bureau does not believe that this action by the Forum demonstrates sufficient
progress to warrant the granting of the requested three-month extension. Moreover, it is not
readily apparent to us what might be expected to be accomplished by the granting of the
extension request, in light of the fact that: (1) the only further progress of the Forum before
the end of this year is likely to be the completion of equipment testing; (2) CTIA and PCIA
have conceded that there is the likelihood that the equipment necessary to provide TTY
access to 9-1-1 over digital wireless systems will not be commercially available until after
January 1, 1999; and (3) the draft workplan gives no indication as to how soon solutions
will be implemented.
8. The Bureau understands, however, the complexity of the technical obstacles facing
the Forum, as well as the difficulty of developing solutions that are acceptable to multiple
carrier, manufacturing, government, and consumer groups. We will therefore grant a limited
extension of the deadline until November 15, 1998 in order to provide additional time
for the deficiencies in the draft workplan to be addressed, and to enable the Forum to
complete certain activities currently underway and to demonstrate a degree of progress that
would justify a further extension.
9. Specifically, we adopt the following requirements in this Order:
(1) The current draft plan for the testing of digital wireless equipment must be
finalized.
(2) The draft workplan must be finalized, and approval of the workplan must be
obtained from all groups participating in the Forum. We note, in this regard,
that it will be necessary for the workplan to address consumer concerns. For
example, consumer representatives recently provided to the Forum member
groups a list of criteria that the consumer representatives would like to be
incorporated into any solutions implemented by the Forum. See Appendix.
(3) The test plan and the workplan must be submitted to the Bureau by October
30, 1998.
Based on our review of these documents, the Bureau will decide whether a further extension
of the deadline, to January 1, 1999, is warranted. We also recognize, of course, that,
given the admission made by CTIA and PCIA regarding the status of compliance efforts,
further action by the Commission will be necessary to determine whether there is any basis
to continue the Commission's suspension of its enforcement of Section 20.18(c) beyond
January 1, 1999.
10. To help inform our decisionmaking and to advise the Commission, we also need
to gather as much information as possible regarding the Forum's past progress and future
activities, as well as the work being undertaken by individual wireless equipment
manufacturers and carriers. We wish to underscore that we anticipate that information we
obtain will play an important role by informing subsequent decisions regarding the
advisability of continuing the suspension of the Commission's enforcement of the provisions
of Section 20.18(c) of the Commission's Rules. Thus, we request that CTIA, PCIA, and
other industry member groups represented in the Forum respond to the questions listed in
this paragraph. We request that responses to the questions be submitted to the Bureau by
October 30, 1998. In addition, wireless equipment manufacturers and carriers who are not
participating in the Forum may also provide related information, so that we will be able to
evaluate their efforts to comply with our rules.
þ What specific actions are being taken by individual carriers to comply with the
notification requirements outlined in the E911 Reconsideration Order (i.e., the
requirement that carriers make every reasonable effort to notify current and potential
subscribers that they will not be able to use TTYs to call 911 with digital wireless
devices and services )?
þ Has any carrier been able to meet the October 1, 1998, deadline? If so, what steps has
the carrier taken that led to its ability to meet the deadline?
þ For each of the digital technologies (i.e., TDMA, CDMA, GSM, and iDEN), have
manufacturers been able to determine the root technical causes for the incompatibility
between TTY devices and their systems? If so, what is the nature of these root
technical causes, for each technology?
þ What potential solutions have been submitted to appropriate standard-setting bodies or
forums for their review and analysis?
þ Are there any segments of the wireless industry that might be crucial to the
development of the potential solutions that are not represented in the Forum, e.g.,
manufacturers of Inter-Working Functions (IWF), who would have to modify IWF
software as part of a data solution) and is their representation necessary for
implementation of such solutions?
þ Explain the possible negative consequences of any potential solutions for TTY users,
e.g., the reduction in throughput that would result from the insertion of additional bits
between transmitted characters.
þ For each of the digital technologies, what would be the timetable for implementation of
a data solution on an equitable basis with voice services offered?
þ If an extension were granted in order to reach a long-term solution to the problem of
incompatibility between TTY devices and various digital systems, what could each
carrier do in the interim to accommodate TTY users on wireless systems?
þ At what laboratory location will the upcoming testing of digital wireless phones be
conducted? Will carriers ensure that representatives from all Forum member groups
participate in the testing?
þ Will field tests be conducted, including tests involving actual TTY users, following
completion of the laboratory tests?
þ Have carriers provided equipment and wireless service to TTY users so that users can
conduct their own field tests? If equipment and service have not been provided, what
obstacles have prevented carriers from doing so? What are the carriers' plans for
providing equipment and service to facilitate future field tests by TTY users?
11. Accordingly, IT IS ORDERED that the request submitted by the Cellular
Telecommunications Industry Association and the Personal Communications Industry
Association for an extension of the October 1, 1998, deadline to January 1, 1999, for
compliance with Section 20.18(c) of the Commission's Rules IS DENIED.
12. It is FURTHER ORDERED that an extension of the suspension of enforcement of
Section 20.18(c) of the Commission's Rules in the case of digital wireless systems, from
October 1, 1998, to November 15, 1998, IS GRANTED for the purposes described in this
Order.
13. This action is taken pursuant to delegated authority under Section 0.331 of the
Commission's Rules and paragraph 158 of the E911 Reconsideration Order.
FEDERAL COMMUNICATIONS COMMISSION
Daniel B. Phythyon
Chief, Wireless Telecommunications Bureau APPENDIX
September 10, 1998
To: TTY Forum
Fr: Consumer Representatives
The CTIA has said that most of the consumer criteria previously submitted were
not usable by the TTY Forum because the criteria covered marketing and
distribution as well as design. Marketing and distribution issues for a possible
one-phone-model-per-technology short-term plan will be taken up with CTIA s
senior management, as suggested by them.
This contribution is a new set of criteria to address only functional characteristics
of the solutions. The new criteria also reflect new information from the Forum
since the first list was drawn up. It is intended to cover any solution.
1. The character error rate should approximate that of AMPS, which has been
demonstrated at <1% for stationary calls. More research on AMPS
performance with TTY would be useful to assist in specifying a range of
conditions.
2. The TTY caller must be able to visually monitor all aspects of call progress
provided to voice users. Specifically, the ability to pass through sounds on
the line to the TTY (so that the user can monitor ring, busy, answered-in-
voice, etc.) should be provided.
3. There must be a visual indication when the call has been disconnected.
4. A volume control should be provided.
5. The TTY user must have a means of tactile (vibrating) ring signal indication.
6. The caller must be able to transmit TTY tones independent of the condition
of the receiving modem. (This is to permit baudot signalling by pressing a
key, to let a hearing person know that the incoming call is from a TTY.)
7. The landline party s TTY must not require retrofitting in order to achieve the
desired error rate.
8. The wireless party s TTY may require retrofitting, or a new model TTY to be
developed, or the use of a portable data terminal such as a personal digital
assistant.
9. VCO and HCO should be supported where possible.
10. Reduction of throughput (partial rate) on Baudot is highly undesirable and
should not be relied upon to achieve compliance (see #7). It may be useful
as a user-selectable option to improve accuracy on a given call.
11. Call information such as ANI and ALI, where provided in wireless voice,
should also be provided for TTY calls.
12. The solution need not support little-used or obsolete TTY models, but in
general should support the embedded base of TTYs sold over the past ten
years. The landline equipment supported must not be limited to that used in
Public Service Answering Points (911 centers).
13. Drive conditions must be supported, again using AMPS as a benchmark.